Regulations Governing Application of Agreements for the Avoidance of Double Taxation with Respect to Taxes on Income Article 20
When a payment that consists of various types of income applies for the provisions of a DTA, these various types of income shall, based on their respective natures, be classified into appropriate income items pursuant to the provisions of such DTA, and the provisions of each identified item of income under that DTA shall govern the relevant applications.
中文原文 適用所得稅協定查核準則第20條
申請適用所得稅協定之給付包括不同類型所得項目者，應依其性質按適用之所得稅協定規定歸屬各項目適當之所得，分別適用之。